If your UK small business sells only in Great Britain, the EU GPSR does not apply to those sales: GB stays under the UK General Product Safety Regulations 2005. It does apply when you sell into Northern Ireland or the EU. Then you need a responsible operator established in Northern Ireland or the EU, plus product and listing details.
So the real question is where you want to sell, and what each route needs. Below are the three routes side by side and a fictional maker deciding. If you already want Northern Ireland or EU customers, our EU Responsible Person service provides the operator the rules ask for.
Where you sell decides which rules apply
The GPSR (Regulation (EU) 2023/988) applies to consumer products placed on the market from 13 December 2024, filling the gaps where no sector-specific EU rules cover a risk. For a GB-based business, here is what changes as you add destinations.
| Where you sell | Product safety law for those sales | Who must be responsible, and where they must be established | What the product or parcel must show | What the listing must show |
|---|---|---|---|---|
| GB only (England, Scotland, Wales) | UK General Product Safety Regulations 2005, not the EU GPSR | For UKCA or CE goods: a UK-established importer or authorised representative where you use one. For roles under other UK product laws, such as cosmetics, see our UK Responsible Person guide. | For UKCA or CE goods, your name and postal address as manufacturer (and the importer’s, for imported goods) normally appear on the product or its packaging | The EU GPSR listing rules do not apply to GB sales |
| GB plus Northern Ireland | EU GPSR for the products you place on the NI market | A responsible economic operator established in Northern Ireland or the EU. A PO box does not count. | On the product (or, if its size or nature prevents it, the packaging or an accompanying document): your name and postal and email address as manufacturer, and a batch, serial or other identifier. On the product, its packaging, the parcel or an accompanying document: the responsible operator’s name and contact details | Manufacturer’s name, postal and email address; responsible person’s details; product identifiers and a picture; warnings in a language buyers easily understand |
| GB plus EU countries | EU GPSR, plus EU sector laws (such as toys or electrical goods) where they apply | An economic operator established in the EU: an EU manufacturer, an authorised representative with a written mandate, the importer, or, only if none exists, a fulfilment service provider | As for Northern Ireland | As for Northern Ireland, with warnings suited to each country’s buyers |
Behind the NI and EU rows sits the same groundwork: before placing a product on the market, the manufacturer does an internal risk analysis and draws up technical documentation, kept for 10 years.
Selling only in Great Britain
If all your customers are in England, Scotland and Wales, the EU GPSR is not your rulebook. GB continues to recognise CE marking for many product types, with no end date stated, though medical devices, construction products and some other sectors have separate rules. The Product Regulation and Metrology Act 2025 lets the government update UK product rules, and a consultation on a new framework closed on 23 June 2026, but no dates for new GB rules are confirmed. For GB roles by product type, see UK Responsible Person requirements by product type.
Shipping to Northern Ireland
Northern Ireland is a domestic sale, but for product safety it follows EU rules: the GPSR applies there, so a parcel to Belfast needs what an EU parcel needs.
Who can be your responsible operator
The operator must be established in Northern Ireland or the EU. Gov.uk explains that “established” means a presence there, such as a registered office or permanent place of business; for a sole trader it can be where you live. A PO box is not enough. A GB business has three realistic options:
- Use your own NI premises, as in a gov.uk case study, if you have them.
- Sell through an NI importer: if you wholesale to an NI business that brings your goods in from GB, it is likely to be the importer. This does not cover orders you send direct to NI customers.
- Appoint an authorised representative established in Northern Ireland or the EU, with a written mandate.
What goes on the product and parcel
The operator’s name and contact details must appear on the product, its packaging, the parcel or an accompanying document. Gov.uk says that document can be a despatch note or receipt, and need not sit inside the product’s packaging as long as it travels with it. Products must also carry a batch, serial or other identifier.
If you would rather not ship to Northern Ireland
Some small sellers have decided a handful of NI orders is not worth the set-up. That is a business choice. If you make that choice, switch off Northern Ireland delivery on every channel you sell through, including marketplaces and your own website.
Selling into the EU
A product cannot be placed on the EU market unless an economic operator established in the EU is responsible for it. That operator must regularly check the product against its technical documentation and labelling rules, and show evidence of those checks on request. Our GPSR explainer covers these duties in general.
The useful overlap: because Northern Ireland accepts an operator established in the EU, one EU-established representative can serve both. Gov.uk says a GB business that has already taken steps to trade in the EU should not have to make any additional changes to operate in NI.
Two extras apply. CE-marked goods such as toys and electrical products need a Declaration of Conformity under their own laws; a product under the GPSR alone needs the risk analysis and technical documentation instead. And producer rules apply country by country: in Germany, businesses that first make packaged goods available there must register with the LUCID Packaging Register; France issues EPR unique identifiers (IDUs); and Amazon asks sellers for these numbers. See EPR registration for Germany and France.
Etsy, Amazon or your own website: does the platform matter?
Not for the core duties. The listing rules attach to any online or distance-sales offer, so Etsy, Amazon and your own site all need the same details for NI or EU buyers. What differs is where you enter them:
- Marketplaces such as Etsy and Amazon must let sellers enter product safety information. Hosting your listing does not make the marketplace your responsible person.
- Your own website has no form, so you add the details to each product page yourself.
Worked example: a fictional GB maker decides
Marsh Lane Studio is a fictional business, used only to show the reasoning. It is a Leeds sole trader printing cotton cushion covers and tote bags, selling on Etsy and its own website, GB only so far. Customers in Belfast and Dublin keep asking for delivery, and Amazon.de is a maybe for next year.
- GB orders: nothing changes because of the GPSR.
- Belfast and Dublin: both need an operator established in Northern Ireland or the EU. With no NI premises, the owner appoints one EU-established authorised representative with a written mandate, covering both.
- Before the first order: she writes a risk analysis and technical documentation for each product type, kept for 10 years, adds a batch code and her own name and postal and email address to the sewn-in label, and prints the representative’s name, postal and email address on her despatch note.
- Listings: she fills in Etsy’s product safety fields and adds the same details, a product code and warnings to each website page.
- Amazon.de: she waits. Germany also means LUCID packaging registration and warnings German buyers can easily understand.
One appointment and the paperwork above cover the GPSR for both new markets; check each country’s producer rules too, and GB trading carries on as before.
Your next step
Decided to ship to Northern Ireland or the EU? Start with the operator. Our EU Responsible Person service is run by an Estonian company, so it is established in the EU, and gov.uk confirms that an operator established in the EU is accepted for Northern Ireland as well as the EU. We review your documents before you sign up. For your own risk analysis and technical documentation, our compliance template packs are a structured starting point; a template alone does not make a product compliant, which still takes a real risk analysis, testing where relevant, and checks.
Frequently asked questions
Does the GPSR apply to UK small businesses?
Only to their sales into Northern Ireland or the EU. Sales in Great Britain stay under the UK General Product Safety Regulations 2005. The gov.uk Northern Ireland guidance does not set separate rules for small businesses.
Do I need an EU responsible person to sell to Northern Ireland on Etsy?
You need a responsible operator established in Northern Ireland or the EU. Without NI premises or an NI importer, the route is an authorised representative established in Northern Ireland or the EU. Etsy does not become your responsible person by hosting the listing.
Can my GB company be the responsible operator for Northern Ireland?
Only with a real presence in Northern Ireland or the EU, such as premises. A GB address does not count, nor does a PO box.
Do hobby sellers need to comply?
Gov.uk says occasional supplies by hobbyists or charities are, in principle, not a commercial activity, but it is judged case by case, including how regularly you sell. If you sell regularly, do not rely on it.
Sources
- gov.uk: EU Regulation 2023/988 on general product safety, detailed guidance (Northern Ireland)
- gov.uk: EU Regulation 2023/988 on general product safety, factsheet (Northern Ireland)
- gov.uk: Placing UKCA or CE marked products on the market in Great Britain
- gov.uk: Refining the law to better protect consumers
- EUR-Lex: Regulation (EU) 2023/988 (General Product Safety Regulation)
- Stiftung Zentrale Stelle Verpackungsregister: checking a registration status
- data.gouv.fr: SYDEREP producer register (ADEME)
- Amazon: extended producer responsibility compliance